State v. Thomas (and Vice Versa)

Summary

The court affirmed the trial court’s grant of a new trial because the State failed to disclose that it had offered its witness assistance with a pending felony charge in exchange for testimony. The undisclosed agreement was favorable impeachment evidence, was not reasonably discoverable by the defense, and was material because the State’s case depended heavily on weak accomplice testimony and limited corroboration. The court also held that the trial evidence was legally sufficient under Georgia’s corroboration requirement, so a retrial was not barred by double jeopardy.